CEO Update 119
HHS Includes Behavioral Healthcare Providers in Provider Relief Fund Phase 3 Distribution
The Department of Health and Human Services (HHS) on Thursday announced an additional $20 billion is available from the Provider Relief Fund (PRF) for healthcare providers to recover Covid-19-related financial losses and changes in operating expenses.
HHS highlighted behavioral healthcare providers in its announcement and encouraged these providers to apply for this latest round of funding. HHS has developed a list of behavioral healthcare providers who are now eligible for funding, such as addiction counseling centers, mental health counselors, and psychiatrists.
“Our behavioral health providers have shouldered the burden of responding and confronting this expanded challenge triggered by the pandemic,” HHS said in the announcement. “When traditional face-to-face counseling was restricted and new telehealth flexibilities were put in place in response to the pandemic, many behavioral health providers invested in and adopted telehealth technologies to continue providing patient care.”
Providers are encouraged to apply early. Be sure to apply between Monday, Oct. 5 through Friday, Nov. 6, 2020.
Eligible providers include behavioral healthcare providers who had previously not been eligible (presumably because they did not participate in Medicare or Medicaid); providers who had already received PRF payments; and providers who began practicing in 2020 and were therefore not eligible to apply previously.
Providers who apply will be considered first for the 2% of patient care revenue that has already been made available. If they have not yet received payments from the PRF amounting to 2% of patient care revenue, they will receive funding to reach that amount.
In addition, those who apply will receive an add-on payment above the 2% from the $20 billion allocation based on the following criteria:
- Change in operating revenues from patient care;
- Change in operating expenses from patient care, including expenses incurred related to the coronavirus; and
- Payments already received through the prior PRF distributions
All providers receiving PRF funding will be required to accept the associated terms and conditions including reporting requirements.
HHS said it plans to hold webinars to assist with the application process.
HHS Provider Relief Fund Reporting Requirements Change Terms for Recovering Lost Revenue
The Department of Health and Human Services (HHS) has issued guidance that contradicts the department’s June FAQ about calculating lost revenue from Covid-19 that may be recovered through the Coronavirus Aid, Relief, and Economic Security Act’s (CARES) Provider Relief Fund (PRF).
In the June FAQ, HHS said hospitals could “use any reasonable method of estimating the revenue during March and April 2020 compared to the same period had Covid-19 not appeared.” This latest guidance defines lost revenue that may be recovered as being limited to “a negative change in year-over-year net patient care operating income.” The guidance further specifies that providers generally will only be able to apply their PRF payments to lost revenue up to a facility’s net patient operating income for 2019.
As HHS announced previously, providers who have received more than $10,000 from the PRF are required to submit a report by Feb.15, 2021, on the use of those funds through Dec. 31, 2020, and, if necessary, a second and final report by July 31, 2021.
The PRF funding provided through the CARES Act and subsequent legislation was intended to reimburse eligible providers for healthcare-related expenses and lost revenues attributable to Covid-19. HHS had included a general commitment to reporting on the use of the PRF funds in the terms and conditions that PRF fund recipients agreed to for the funding. Previously HHS said it would issue detailed reporting instructions by Aug. 17, 2020 and the reporting system would be available Oct. 1. The reporting system is not yet available.
“We urge you to rescind the changes included in the Sept. 19 guidance regarding how lost revenue may be calculated,” NABH President and CEO Shawn Coughlin wrote in a letter to HHS Secy. Alex Azar on Oct. 1. “Please clarify that providers may continue to rely on the June guidance as an alternative and equally valid approach to calculating lost revenue attributable to Covid-19 and eligible for reimbursement with funding from the PRF.”
Please contact your U.S. senators and representatives today and ask them to urge the White House and HHS to reinstate the Covid-19 PRF reporting requirements that HHS outlined in June. Providers must be able to use these funds to recover any revenue lost due to Covid-19, rather than be limited by these new details from HHS.
NABH Sends 2021 OPPS Rule Comment Letter to CMS
NABH this week submitted comments to the Centers for Medicare & Medicaid Services (CMS) concerning partial hospitalization program (PHP) provisions in the agency’s 2021 outpatient prospective payment system (OPPS) proposed rule.
In a letter to CMS Administrator Seema Verma, NABH President and CEO Shawn Coughlin said NABH supports provisions in the rule that continue using the geometric mean per diem cost methodology to set the rates for PHPs. The association also supports maintaining a separate cost floor for the Community Mental Health Center PHPs and the Hospital-based PHPs, the letter noted.
“We agree that it is important that the per diem rates not fluctuate too greatly from year to year to provide stability for PHP providers,” Coughlin wrote in the letter. “In order to ensure stability in future rates, we recommend that CMS consider incorporating an annual adjustment to the cost floor in order to ensure that it reflects updated cost information and continues to help minimize the impact of significant changes in the median costs.”
NABH’s letter also expressed concerns about the decrease in the rate for ambulatory payment classification (APC) 5822 Level 2 Health and Behavior Services, and urged the agency to consider continuing telehealth coverage for PHP services and coverage for associated facility fees so individuals with serious behavioral health conditions can continue to access critical services.
SAMHSA Releases ‘My Mental Health Crisis Plan” Mobile App
The Substance Abuse and Mental Health Services Administration (SAMHSA) this week released “My Mental Health Crisis Plan,” a new mobile app that allows individuals with serious mental illness (SMI) to create a plan to help guide their treatment during a mental health crisis.
A SAMHSA announcement said the app was developed through SMI Adviser, a project that SAMHSA administers with funding from the American Psychiatric Association. The new resource provides a step-by-step process for individuals to create and share a psychiatric advance directive (PAD), a legal document that includes a list of instructions and preference that the individual wishes to be followed during a mental health crisis if the person is unable to make his or her own decisions.
My Mental Health Crisis Plan also allows individuals to state clearly which medications to use and not to use, preferences for hospitals and mental health professionals, the names of trusted persons who can act on their behalf, and more.
The mobile app is available in the Apple App Store and Google Play.
JAMA Study Examines PTSD Risk Factors Among First Responders in a Crisis
First responders in a major crisis may be most likely to experience post traumatic stress disorder (PTSD) if they are older and affected personally by the disasters, a new JAMA study has concluded.
For the study, researchers studied data from more than 56,000 first responders after a 9.0 magnitude earthquake that struck Japan in March 2011 that led to nearly 16,000 deaths. The responders were surveyed several times during a six-year period, and researchers found that although only 7% of the study group likely had PTSD overall, being personally affected by the disaster meant a 96% increase in likelihood of PTSD.
“Given these findings, in the future, first responders’ PTSD symptoms might be mitigated by shortening deployment length, avoiding post-deployment overtime work, and paying special attention to the needs of personal experience of the disaster or older age,” the study said. “Efforts to alleviate responders’ initial symptoms will be required.”
Please Complete the 2020 NABH Annual Survey!
The 2020 NABH Annual Survey opened in late August and NABH members should have received personalized links to the survey from consulting firm Dobson DaVanzo.
If you have not received a link, please click here and follow the instructions to submit your survey today. Your feedback will help inform and improve NABH’s advocacy efforts.
The survey closes on Saturday, Oct. 31. Thank you for your time!
Fact of the Week
Researchers from the University of Washington used data from the National Survey of Drug Use and Health to identify risk factors for suicide among individuals with mental health challenges who had criminal justice system involvement. They found that while there was a higher frequency of suicide attempts in all populations that had been involved with the criminal justice system, those who had been recently arrested were at the highest risk for suicide compared with those on parole or probation. The results suggest that prioritizing suicide prevention and mental health services after arrest could have significant impacts on this population.
For questions or comments about this CEO Update, please contact Jessica Zigmond.